Effective as of August 2, 2006

Xap Corporation ("Xap"), the company that operates MassMentor, has adopted the following privacy policy for the information collected at this website.

As MassMentor evolves, we may update this privacy policy to reflect changes in the manner in which we deal with personal information, whether to comply with then-applicable regulations and self-regulatory standards or otherwise. The privacy policy posted here will always be current. We encourage you to review this statement regularly.

WHAT THIS PRIVACY POLICY STATEMENT COVERS:

• MassMentor privacy policy and its exceptions
• The personal identifying information we collect
• Reasons we collect personal identifying information
• Minimum age of 13 required to establish an account
• Ways in which personal identifying information may be used
• With whom personal identifying information may be shared
• Security measures to protect information entrusted to Xap and MassMentor
• Cookies
• Links
• Modifying and deleting your information
• Amending this Privacy Policy
• Questions

MASSMENTOR PRIVACY POLICY AND ITS EXCEPTIONS
Except as set forth below, personally identifiable data you enter on MassMentor is not made available or distributed to third parties, except with your express consent or at your express direction. In particular, MassMentor and Xap will not give, sell or provide access to your personal information to any company, individual or organization for its use in marketing or commercial solicitation or for any other purpose, except with your express consent, at your direction, as is necessary for the operation of this site, or pursuant to one of the exceptions listed below.

EXCEPTIONS TO THE PRIVACY POLICY
There are limited exceptions to the MassMentor privacy policy. When required by law to comply with any valid legal process such as a search warrant, subpoena, statute, regulation or court order, Xap will supply such information contained in your MassMentor account as Xap reasonably determines, based on the advice of counsel, it is legally required to supply. In addition, Xap may release specific information relevant to special cases, such as a physical threat to you or others or an attempted breach of security on the MassMentor site.

THE PERSONAL IDENTIFYING INFORMATION WE COLLECT
MassMentor collects personal identifying information from you including, but not limited to, your name, date of birth, address, e-mail address, telephone number, grade level, parent's, contact information, Social Security number, such additional information as you choose to include in your user profile or are required to provide by the college and financial aid applications that you choose to complete, and information associated with activities you have undertaken on MassMentor.

REASONS WE COLLECT YOUR PERSONAL IDENTIFYING INFORMATION
MassMentor collects personal information from you primarily for three reasons. The first reason is to perform a task on MassMentor, such as filling out a specific college admission application, requested by you. The second reason is to enable you to submit in a convenient and efficient manner information that is likely to be needed when you complete college admission, financial aid and other applications and forms made available through MassMentor or undertake a scholarship search on MassMentor, and the third reason is to enable Xap to respond to your questions or contact you when necessary in connection with the functioning of MassMentor. When the effective functioning of a MassMentor module does not require personal information, none is collected, and any such module can be accessed without opening an account or providing any personal data.

When you log on to MassMentor, your browser will automatically transmit to MassMentor's server the IP address of your computer and type of browser you are using. Although your browser transmits the IP address of your computer, MassMentor does not associate this IP address with any personally identifiable information regarding you. MassMentor does not collect any personally identifiable information other than what users submit and their browsers transmit.

MINIMUM AGE OF 13 REQUIRED TO ESTABLISH AN ACCOUNT
MassMentor will not collect any information from persons who are not yet 13 years old. If you are under 13 years of age, you are not authorized to create an account on MassMentor, but you can utilize those portions of MassMentor that do not involve the collection of personal information from users.

If you are 13 years of age or older, you are encouraged to create an account on MassMentor and to utilize all of MassMentor, which will help you plan, prepare and pay for your future education.

WAYS IN WHICH PERSONAL IDENTIFYING INFORMATION MAY BE USED
MassMentor will use your personal identifying information to complete the following forms and surveys, to obtain information for you and to effect transactions on your behalf, in each case only upon your instructions to do so:

• Complete applications for admission
• Complete financial aid applications
• Complete financial aid calculators
• Complete a scholarship search
• Complete freshman planners, which can assist you in selecting courses and otherwise planning to meet admission requirements
• Communicate your requests for information or material to colleges or other institutions you have specified

Your personal identifying information may also be used for the following purposes:

• We may use your identifying information to help diagnose problems with MassMentor's server and to administer the MassMentor website.
• Summary data representing a compilation of aggregate data representing MassMentor users may be collected by Xap and provided to various entities including colleges and other educational institutions represented on MassMentor. NO PERSONAL IDENTIFYING INFORMATION IS MADE AVAILABLE AS PART OF THESE SUMMARY REPORTS. Some examples of summary data are the number of monthly visitors to the site, the number of admission applications submitted over MassMentor, and the MassMentor functions utilized by students in specified age or grade ranges.

WITH WHOM PERSONAL IDENTIFYING INFORMATION MAY BE SHARED
Any time you request that we perform a task that involves a transfer of data, the data related to the performance of that task will be made available to a recipient you designate or to a service provider assisting us in completing that task. For example:

• If you submit an application for admission to a college or other educational institution, the personal data required to complete that application will be provided on your behalf to the admissions office of the institution to which you are applying.
• If you request that your data be transferred to FAFSA on the Web to help you fill out your federal financial aid application, data relevant to that application will be provided to a processor specified and authorized to process your financial aid applications (FAFSA) by the U.S. Department of Education.
• If you request that a college or other educational institution send you material, your contact information will be provided to that institution.
• If you request that information saved in your MyMentor Portfolio be made available to your high school counselor, high school counseling office or someone else you designate to perform in a comparable role, Xap will permit those whom you have authorized to view personally identifying information about you.

Note: If you begin an application for admission to a college or other educational institution, your name and other data entered on that application may be provided to the admissions office of that institution, even though you have not yet submitted a completed application to that institution.

SECURITY MEASURES TO PREVENT MISUSE OF INFORMATION ENTRUSTED TO MassMentor
MassMentor causes the data you input to be encrypted when in route between your browser and the MassMentor server and when in route between the MassMentor server and some other browser or server. This practice helps prevent unauthorized third parties from intercepting and gaining access to your private data during transmission over the Internet. MassMentor uses 56-bit, Secure Socket Layer encryption supported by both Netscape's and Microsoft's browsers.

Data residing on the MassMentor server is password protected, and access is provided only to the account holder who created the password, anyone to whom that account holder entrusted the password, and those employees of Xap who require such access to administer and maintain the MassMentor system or to provide requested customer support to users of MassMentor. Each Xap employee who has access to the data residing on the MassMentor server has agreed in writing to respect the privacy of all such personal data.

COOKIES
A cookie is a small file that a website transfers to a user's computer, which may then be stored on its hard drive. MassMentor uses cookies to remember you and personalize your web-viewing experience by keeping track of your session when logged on to MassMentor. Cookies enable you to maintain continuity as you move from page to page on MassMentor and to avoid the nuisance of being asked to provide the same information repeatedly. Cookies also allow us to make sure that only your browser can exchange information regarding your account with our servers. Cookies cannot be used to steal personal information or to gain access to information that you did not directly provide. The cookies we use are set when you log on to MassMentor and are erased when you log off MassMentor or completely close your browser.

Don't want cookies?
Most browsers are initially set to accept cookies. If you don't want cookies, you can set your browser to disable or refuse cookies or to alert you when cookies are being used. You should note, however, that various MassMentor services might not function properly when cookies are not utilized.

LINKS
MassMentor hosts links to other sites or resources, and you may link to one of those sites or resources for a variety of purposes, such as visiting an official college website. These sites and resources have privacy policies that may differ from that of MassMentor, and for your protection, we recommend that you read and understand the privacy policy at any website prior to providing personal information on that website. Xap is not responsible for the privacy practices or the content of any websites to which MassMentor links or for the conduct of persons operating those websites. Xap, the colleges, the associations of colleges and the agencies represented on MassMentor do not have control over, and do not endorse such external sites and resources. Xap, the colleges, the associations of colleges and the agencies represented on MassMentor shall not be liable for any content, advertising, products or other materials on or available from such sites or resources. In addition, Xap, the colleges, the associations of colleges and the agencies represented on MassMentor shall not be responsible or liable, directly or indirectly, for any damage or loss caused or alleged to be caused by or in connection with use of or reliance on any such content, advertising, products or materials on or available through any such site or resource.

MODIFYING AND DELETING YOUR INFORMATION
You may update, otherwise modify or delete from the data stored on MassMentor any personal information you previously provided. To modify personal information, (i) log on to MassMentor, (ii) access either your user profile or an application containing the information you want to change, and (iii) modify that information using standard word-processing techniques. To delete personal information that is not a required field to be completed in your profile, (i) log on to MassMentor, (ii) access your user profile, and (iii) delete the information you want to remove from MassMentor using standard word-processing techniques and (iv) save the change. To delete personal information that is a required field to be completed in your profile, you will need to contact Xap at 1-800-GOTO-XAP and request that your profile be deleted. Please recognize that if you delete information, it will no longer be available on MassMentor so that, for example, if a college to which you previously submitted an application were to attempt to retrieve that application from MassMentor after you made the deletion the deleted information would no longer be accessible. Similarly, when accessed over MassMentor, information that has been updated or otherwise modified will appear in its then-most current form, rather than in the form in which it may have been submitted at some earlier time.

AMENDING THIS PRIVACY POLICY
Xap may amend this Privacy Policy from time to time. Unless legal obligations require faster implementation, if Xap makes any substantial changes to this Privacy Policy concerning use of your personal information Xap will notify you by posting a message on the MassMentor homepage for at least thirty days. Thereafter, the new privacy policy will apply to all data previously submitted or subsequently submitted to MassMentor, unless such use if prohibited by law. If you do not wish to have your information used in accordance with a newly posted privacy policy, you should modify or delete the relevant information in the manner described in the preceding section, "Modifying and Deleting Your Information."

QUESTIONS
If you have any questions about this Privacy Policy and the privacy practices on this site, you may contact us at privacy@massmentor.edu.